The terms arrangements, successor and control are specifically defined for the purposes of the provisions restricting group relief when companies leave a group.
Meaning of arrangements for the purposes of denying group relief
Arrangements (of any kind, whether or not in writing1) will fall within the provisions at D2.251 if they:
- Ìý
•ÌýÌýÌýÌý involve two companies in a group and the arrangements could (broadly) have the effect of allowing2:
- Ìý
–ÌýÌýÌýÌý the first company (or any successor) to leave one group and join another at some time during or after the current period
- Ìý
–ÌýÌýÌýÌý a person/persons (other than the first or second company) to have or obtain control of the first company but not of the second company at some time during or after the current period, or
- Ìý
–ÌýÌýÌýÌý a third company to start to carry on the whole or a part of a trade (as a successor to the trade) at some time during or after the current period, where at a time during the current
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